Small Win on PSR Documentation Requirements

Earlier this year, some growers reported that California Department of Food Agriculture (CDFA) inspectors were requesting documentation not only for custom harvesters and hullers, requirements growers were already accustomed to, but were also requesting this documentation from the processors they were sending their tree nuts to. These requests included sanitation logs, training records, and water testing results.

Currently, most processors are not regulated under the Produce Safety Rule (PSR) but the Preventive Control for Human Foods. This additional documentation requirement created confusion and added yet another layer to an already burdensome regulatory mandate as growers would have needed to maintain documents from three different steps of the process.

After the Western Tree Nut Association (WTNA) raised these concerns with CDFA and engaging in continued follow-up, the Association was able to secure clarity and some regulatory relief. CDFA consulted with the Food and Drug Administration (FDA) and confirmed that growers are not required to maintain PSR-related documentation for hullers or processors. These operations will instead undergo their own inspections to verify compliance directly.

Going forward, growers will only need to maintain PSR documentation for their custom harvesters, a small but meaningful reduction in paperwork at a time when regulatory obligations continue to grow. This outcome eliminates one more unnecessary requirement and ensures that responsibilities fall where appropriate. The Association will continue working to reduce burdensome documentation wherever possible.